St. Amant v. Thompson
20 L. Ed. 2d 262 · Supreme Court of the United States · 1968
Facts
Petitioner St. Amant, a political candidate, broadcast a speech quoting an individual who accused respondent Herman A. Thompson, a deputy sheriff, of corrupt connections. Thompson sued St. Amant for defamation, and after initial conflicting rulings in Louisiana courts regarding the application of the "actual malice" standard, the Louisiana Supreme Court found sufficient evidence of reckless disregard and reinstated a judgment for Thompson.
Issue
Did the Louisiana Supreme Court correctly interpret and apply the "actual malice" standard from New York Times Co. v. Sullivan in sustaining a judgment for damages in a public official’s defamation action?
Holding
No, the Supreme Court reversed the Louisiana Supreme Court's judgment, holding that Thompson failed to prove St. Amant acted with actual malice. The Court found that the evidence did not demonstrate St. Amant entertained serious doubts about the truth of the statements or had a high degree of awareness of their probable falsity.
Rule
To establish "actual malice" in a public official defamation case, the plaintiff must prove the defendant published with knowledge of falsity or with reckless disregard for truth. Reckless disregard requires sufficient evidence that the defendant in fact entertained serious doubts as to the truth of the publication, not merely a failure to investigate or heedlessness of consequences.
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